Corporate Sustainability and Social Responsibility Policy

The Seetru Organization

1 Introduction

The Seetru Organization consists of Seetru Ltd, Leser UK Ltd and Blupax Engineering and Industrial Private Ltd., it also includes Seetru Engineering Services which is an operating division of Seetru Ltd. This policy applies to the whole of the Seetru Organization.

2 About Seetru and Our Stakeholders

Seetru was founded in 1949. Our existence and growth has been due to our continual innovation of products and services, and the capabilities, loyalty and dedication of those who work in our organization.

Since our early days we have done things differently and this makes us unique in many ways. In order to ensure our long term sustainability we will continue to invest in our business, and to do things differently. We aim to develop through a shared vision of how we work and where we are heading:“Continually improving and innovating for the profit and well-being of our organization, our employees, our customers, our community and our environment.”We aim to create value through understanding and delivering on our customers’ needs. We aim:“To go above and beyond our customers’ expectations and so to be our customers’ supplier of choice.”

and

“To work in partnership with our suppliers and distributors to achieve a high quality and highly competitive service to our customers worldwide”.

3 Our Social Responsibilities

The objective of our Social Responsibility Policy is to support the long term Sustainability of our operations and our Organization. Our Social Responsibility policy addresses a range of issues which are of great importance to us in the way we work, these include:-

Standards of Behaviour and the rule of law

Our people

Health and Safety

Environmental protection

3.1 Standards of Behaviour and the rule of law

3.1.1 Ethics

Honesty, integrity, openness, professionalism and respect for people and our environment underpin everything we do and are the foundations of our Organization’s business principles.

It is the requirement of the Directors that all our Organization’s operations are conducted to the highest ethical and moral standards and that everyone working within and on behalf of our Organization behaves with the highest ethical standards.

We must always pursue our business objectives with integrity and in complete compliance with both the letter and the spirit of all laws; there are no exceptions.It is the responsibility of all in our Organization to apply and foster these values and standards.

3.1.2 Legal, regulatory and policy compliance

3.1.2.1 Human rights

Seetru, our suppliers, and all entities and individuals within our supply chain, must comply with the following:-

Elimination of child labour: all employees shall have reached the minimum age required for work in the relevant jurisdiction.

Elimination of discrimination: of any kind in respect to hiring, employment and occupation practices.

Compliance with applicable laws and regulations relating to:

working hours, days of rest and safe working conditions; and

employee rights and wage levels.

3.1.2.2 Modern Slavery Act

Seetru, our suppliers, and all entities and individuals within our supply chain, must comply with the UK’s Modern Slavery Act 2015. Specifically, with respect to our own labour practices and those within our supply chain:

all forms of illegal, forced or compulsory labour, slavery and servitude are prohibited;

no individual shall be induced through force, threats, or deception to provide services or benefits of any kind to another or to enable another to acquire, in such a manner, benefits of any kind;

no individuals, groups or organizations shall be involved in the Trafficking of humans. Trafficking means:

Recruiting, transporting, transferring, harbouring, receiving, transferring or exchanging control, or otherwise arranging or facilitating travel of any individual who is travelling while at risk of being exploited through any type of forced or compulsory labour or slavery or servitude.

3.1.2.3 Bribery Act 2010

Bribery is a criminal offence. The Organization prohibits any form of bribery. We require compliance, from everyone connected with our business, with the highest ethical standards and applicable anti-bribery laws. Integrity and transparency are of utmost importance to us and we have a zero tolerance attitude towards corrupt activities of any kind, whether committed by management, employees or by third parties acting for or on behalf of ourselves or our suppliers.

It is prohibited, directly or indirectly, for any employee or person working on our behalf to offer, give, request or accept any bribe, i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or company in order to gain commercial, contractual or regulatory advantage for the Organization, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.

3.1.2.4 US Dodd-Frank Act and Supply Chain Due Diligence

Seetru wish to have supply chain transparency and to facilitate responsible mineral sourcing so as to ensure that our use of minerals in our products does not directly or indirectly finance or benefit armed groups who perpetrate human rights abuses. The minerals subject to these provisions include:-

Tin

Tantalum

Tungsten

Columbite-Tantalite (coltan)(source of Tantalum)

Cassiterite (source of Tin)

Wolframite (source of Tungsten)

Derivative metals of the above minerals

Should any of the above minerals be required in our products or production it is our policy that, where these minerals might originate from, or were processed in, any of the following countries:-

Democratic Republic of Congo

Angola

Burundi

Central African Republic

Republic of Congo

Rwanda

South Sudan

Tanzania

Uganda

Zambia

our supplier must use their best endeavours to trace the original source of supply and confirm that the supply is not supporting armed groups who perpetrate human rights abuses.

3.1.2.5 Due diligence

We must undertake Due Diligence in all aspects of the execution of our business in order to ensure that we discharge all our responsibilities: our legal and regulatory responsibilities as well as our moral and commercial responsibilities.

3.2 Our people

Our people are our most precious resource: it is the attitude, enthusiasm, commitment, capability, flexibility, team working and involvement of each and every one that is the key to the success of our Organisation.

To achieve success for our Organization the work is bound to be challenging, but we aim to make it enjoyable as well. We endeavour to provide excellent conditions of employment and benefits, and to enable our people to participate in the success of our Organization through remuneration and personal development.

Training is important to enhance the capability and competencies of our people, and to offer them the opportunity for personal development.

We aim to:

maintain Investors-in-People accreditation and excellent management of our people and their competencies;

insist upon involvement, ownership and responsibility for all tasks;

work together in our Organization as a team;

understand that enthusiasm, commitment, flexibility, communication and co-operation are vital throughout the Organization, and that each and every person in our Organization has a vital role to play in achieving success.

3.3 Our Health and Safety Policy

We in the Seetru Organisation recognise our duties under the Health and Safety at Work etc. Act 1974 and the accompanying protective legislation. We will endeavour to meet the requirements of this legislation so as to ensure that we maintain a safe and healthy working environment. Our managers and supervisory staff are informed of their responsibilities to ensure they take all reasonable precautions, to ensure the safety, health and welfare of those that are likely to be affected by our undertaking. Responsibilities and arrangements for all health and safety activities are through normal line management in accordance with the organisational chart within the quality manual, reference number ES40121.

The Seetru Organization recognises so far as is reasonably practicable the duty to ensure the following:

To provide and maintain a safe place of work, safe systems of work, safe equipment and a healthy and safe working environment.

To ensure that hazards are identified and regular assessment of risks are undertaken.

To provide information, instruction, training and supervision as is necessary to ensure employees and others are assured of a safe and healthy working environment.

To promote the awareness of health and safety and encourage health and safety best practice throughout our organization.

To ensure we are taking the appropriate protective and preventative measures.

To ensure that we have access to competent advice and are able to secure compliance with our statutory duties.

In order that we can achieve our objectives, and ensure our employees recognise their duties under health and safety legislation whilst at work, we must ensure that we inform them of their duty to take reasonable care of themselves and others that may be affected by their activities. We ensure our employees are informed of their obligations to ensure they co-operate with management and adhere with The Seetru Organization safety rules which are provided within the Employee Safety Handbook.

3.4 Our Environmental Policy

The Seetru Organization are committed to conducting our business responsibly so that we protect our employees, the public and the environment. Our Safety, Health and Environmental commitments are core values of the Organization and integral parts of our business activities.We will meet or exceed all applicable Environmental Laws and Regulations in our business activities.

In addition, we will continually work to achieve the following Environmental Objectives:-

Conserve energy, water and resources, minimising use of natural resources and impact on the environment.

Reuse and recycle where possible and economic, changing to renewable resources where practicable.

Adopt good practice with regard to the reduction of waste, minimising the need for treatment, disposal or emissions.

Use raw materials and dispose of waste in a safe environmentally acceptable manner.

In order to make our behaviour consistent with this Policy Seetru will:

Provide employees with appropriate training necessary to acquire the skills and techniques needed.

Encourage and expect our employees to participate in the development and implementation of our Environmental Programme.

Ensure that all applicable waste is disposed of in a manner compliant with applicable Law and Regulations.

Operate a process of continual improvement to our Environmental Programme and Performance through periodic audit, evaluation, review, and implementation of appropriate corrective and preventive actions.

Aim to achieve ISO14001 accreditation.

This Policy will be reviewed annually by the Directors and amended where necessary in order to remain current. The Organization is committed to this Environmental Policy and will provide sufficient financial and physical resources to meet the objectives.

4 Compliance, monitoring and reporting

Compliance with this policy shall be continuously monitored and reviewed by the Directors annually. Where appropriate each element of this policy is implemented within the Organization through further and more detailed implementation policies, procedures and processes. Each manager is responsible for ensuring that the principles set out in this policy are communicated to, understood and observed by all of our people and for ensuring compliance in their area of responsibility.